Herron Todd White is committed to ensuring the privacy of your personal information. This policy explains how we collect, store, use and disclose personal information and what steps we take to comply with Privacy Laws.
In this policy we use the terms 'we', 'us' and 'our" and 'Herron Todd White', which refers to Herron Todd White (Australia) Pty Ltd, Herron Todd White (Consolidated) Pty Ltd, Herron Todd White (Brisbane) Pty Ltd, Herron Todd White (Cairns) Pty Ltd, Herron Todd White (Canberra) Pty Ltd, Herron Todd White (Central Queensland) Pty Ltd, Herron Todd White (Country NSW & North East Vic) Pty Ltd, Herron Todd White (Darling Downs) Pty Ltd, Herron Todd White (Esperance) Pty Ltd, Herron Todd White (Gippsland) Pty Ltd, Herron Todd White (Gold Coast & NSW Far North Coast) Pty Ltd, Herron Todd White (Melbourne) Pty Ltd, Herron Todd White (MIA) Pty Ltd, Herron Todd White (Newcastle & Hunter Region) Pty Ltd, Herron Todd White (Northern Territory) Pty Ltd, Herron Todd White (North Queensland) Pty Ltd, Herron Todd White (NSW North Coast) Pty Ltd, Herron Todd White (Riverland) Pty Ltd, Herron Todd White (SERA) Pty Ltd, Herron Todd White (South Australia) Pty Ltd, Herron Todd White (South West WA) Pty Ltd, Herron Todd White (Sunshine Coast) Pty Ltd, Herron Todd White (Sydney) Pty Ltd, Herron Todd White (South East NSW) Pty Ltd, Herron Todd White (Western Australia) Pty Ltd and any other company which may become a shareholder of Herron Todd White (Australia) Pty Ltd or Herron Todd White (Consolidated) Pty Ltd.
We abide by the Australian Privacy Principles and are committed to protecting any personal information that we may hold at any time in respect of any individual.
The principles do not apply to certain aspects of the employment relationship and in addition, certain disclosures of personal information between the Herron Todd White Shareholding Entities may not have the same protection as disclosures to third parties.
Collection of personal information is essential for us to be able to conduct our business. If we do not collect personal information, we are unable to do business with you. The types of personal information that we collect are relevant to the service that we provide.
Personal information that we may collect includes name, address, contact details and credit card details.
If personal information concerns particular topics it is regarded as sensitive information. Sensitive information is a sub-category of personal information, which includes information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record and health.
Herron Todd White does not collect this information.
The Australian Information Commissioner has determined that a Credit Provider may include “Corporations that make loans in respect of the provision of goods or services on terms that allow the deferral of payment, in full or in part, for at least seven days.” Herron Todd White may fall within the definition of Credit Provider, but in the normal course of business is unlikely to collect Credit Information apart from your name and address.
Credit Information is certain types of information that includes:
- information about an individual, like their name and address, that we may use to identify the individual;
- information about an individual’s current or terminated consumer credit accounts and individual’s repayment history;
- the type and amount of credit applied for in any previous consumer or credit applications to any credit provider, where the credit provider has requested information;
- information about an individual from a credit reporting body;
- information about consumer credit payments that are overdue for at least 60 days and for which collection activities have started;
- information about an individual on the National Personal Insolvency Index; and
- public available information about an individual’s credit worthiness.
We only collect, hold and use the personal information (which includes any credit information) about you, which is necessary to provide the relevant service to you. We will tell you the main reasons for collecting the personal information when we ask for it; however, generally the purpose includes:
- conduct our business of providing valuation and property consultancy advice and to meet the necessary requirements set down by the Australian Property Institute (API) for these services;
- confirm the various forms of ownership of property affecting the particular service we are providing to you;
- obtain necessary information regarding services, mortgages, leases, licenses etc., affecting the property;
- confirm any encumbrances, licences and registration with local, state or federal governments;
- register your contact and property details;
- maintain our customer sales and rental databases; and
- open a file and maintain billing arrangements with you.
We generally collect personal information directly from you or where it is provided to us, with your instructing authority, from your credit provider. For example, we will collect personal information by:
- conducting a personal interview with you;
- provision by a third party, ie: an instructing financial institution to us;
- searching local, state or federal authorities; and
- instructions received from you by letter, facsimile or email.
Finally, from time to time, we may receive information that we have not asked about you from third parties. We will only keep, use and disclose this information as permitted by law.
In most cases, we will require you to specifically consent to any collection, use or disclosure of your personal information by Herron Todd White. Your consent will usually be required in writing but we may accept your verbal consent in certain circumstances. Sometimes your consent may be implied through your conduct with us, such as when instructing us to conduct a valuation or property consultancy matter.
We store your personal information in a number of ways including:
- electronic systems and devices;
- paper files;
- in telephone recordings; and
- document retention services. This may include storage on our behalf by third party service providers.
Herron Todd White uses cloud based computing systems, which means that personal information may be stored in countries outside of Australia, including New Zealand, India, Philippines and United States of America.
The Internet has brought many improvements in the way Herron Todd White is able to do business. Herron Todd White is continually maintaining and upgrading technology and procedures in this respect to its on-line transactions.
Herron Todd White retains the right to collect any information from any visitor to the Herron Todd White website typically, but not exclusively, for the better understanding of its visitors. For example, how often a visitor goes to a specific page can assist us in focussing our business to the interests and needs of our visitors. Any visitor to the Herron Todd White website who provides any information to Herron Todd White, agrees that Herron Todd White has the right to use that information and the information provided by the visitor will be deemed to be non-confidential. Herron Todd White agrees not to knowingly give any information provided by any visitor to a third party.
Herron Todd White may disclose your personal information to third parties in certain circumstances.
Sometimes we are required or authorised by law to disclose your personal information. For example, we may disclose your personal information to a Court in response to a subpoena. The information that we provide to other organisations will be limited to what is required to provide the service or comply with the law.
Generally, we will not disclose personal information to a party outside Herron Todd White, unless that party is contracted to Herron Todd White to provide administrative services or activities on our behalf. In those circumstances that party is bound by the same privacy rules we follow. Some examples of parties outside Herron Todd White to whom we may disclose your personal information and the reason for disclosure are:
- local, state and federal authorities to obtain property related information, eg: rates, zonings, leases, licences and registrations;
- financial institutions for mortgage security valuations; and
- real estate agents for access to properties for inspections.
From time to time, we may use your personal information to provide you with information about the state of the market and any other services from us that you might be interested in.
If you do not want to receive any of this information, contact us at one of our offices. If you inform us that you no longer wish to receive information about the market, we will not send you any further material. You can however, change your mind about receiving this market information at any time - either way, you just need to let us know.
Herron Todd White does not disclose your personal information to any parties outside Herron Todd White for the purposes of allowing them to direct market their products or services to you.
We take all reasonable precautions to safeguard personal information from loss, misuse, unauthorised access, modification or disclosure as follows:
- external and internal premises security;
- restricted access to personal information;
- confidentiality agreements with contractors and third party organisations; and
- maintaining technology products to prevent unauthorised computer access.
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date.
You may request access to the personal information held by us; such as your name and address details and contact telephone numbers; by calling one of our offices.
If you make a request for more detailed personal information; for example, access to information held in archives; you may incur a fee to cover the cost of retrieval and the supply of this information to you.
All requests for access to personal information will be handled as quickly as possible and we will endeavour to process any request for access within 30 days of having received the request. Some requests for access may take longer than 30 days to process depending upon the nature of the personal information being sought.
Herron Todd White may be required by law to retain personal information for a period of time after you have ceased your relationship with us.
Herron Todd White is not always required to provide access to personal information upon request.
Access may be refused in a number of circumstances such as:
- where the information may relate to existing or anticipated legal proceedings;
- where required or authorised by law; and
- where the request is regarded as frivolous or vexatious.
If access is denied, we will explain why.
Under the Privacy Act 1988 (Cth), you also have a right to request that we correct information that you believe to be inaccurate, out of date, incomplete, irrelevant or misleading. Please advise us by contacting one of our offices.
We will take reasonable steps to correct the information. If we do not correct the information, you can ask us to include with the information held, a statement from you claiming the information is not correct.
If there is a denial to access your personal information or a dispute as to the correctness of any personal information held, we will provide you with reasons for the denial or its refusal to correct the personal information. If you disagree with our decision for the denial or refusal to correct personal information, you may request that we review our decision via the complaints process outlined below.
We will generally need to know who you are in order to provide you with our services. Despite this, in some circumstances, you are entitled to deal with us anonymously or by using a pseudonym (alias); for example, when you are making general enquiries about services we may offer. You may receive a better service, in some circumstances, if you tell us who you are; for example, if you have made a complaint about our services, we may be able to deal better with the complaint if we know who you are and the circumstances of your complaint.
We are committed to resolving any complaint you may have. Complaints can be received in writing, via email, by phone or in person.
If you believe that we have not fulfilled our obligations under the Privacy Act or you do not agree with a decision that we have made in relation to access or updating your personal information, you can make a complaint to us in writing at:
- Chief Executive Officer
- Herron Todd White Australia
- PO Box 61
- Chermside South QLD 4032
- Office of the Australian Information Commissioner
- GPO Box 5218
- Sydney NSW 1042
- Phone: 1300 363 992
- email: email@example.com
- Website: www.oaic.gov.au
Once we have received your complaint we will be in contact with you regarding your complaint and will let you know who will be assisting you, their contact details and the expected resolution date of your issue within 48 hours. If the issue is more complicated, then we may need additional information from you to resolve the complaint. We will keep you updated as to the progress of the complaint.
If you are unhappy with our response, please direct your concerns to the Office of the Australian Information Commissioner (OAIC):
Herron Todd White aims to provide the best possible service across our wide range of property valuation and consultancy services. In doing so, we use the personal information that is provided by you to us on a confidential basis.
We are committed to ensuring the confidentiality and privacy of all personal information it collects during the conduct of our business. In relation to managing personal information, we abide by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).